REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
Tax controversy is a term that describes disputes between taxpayers and taxing authorities, most commonly the Internal Revenue Service (IRS), regarding the amount of tax owed or the application of tax laws. These...more
A couple of years ago, I wrote a blog about the importance of sending any correspondence to the Internal Revenue Service via Registered or Certified Mail or by an approved overnight courier, rather than relying solely on the...more
The U.S. Internal Revenue Service (IRS) appears to be entering a new and far more aggressive phase of enforcement focused on taxpayers claiming Puerto Rico residency and Act 60 (formerly Act 22) incentives or benefits. The...more
Le Conseil d’Etat tranche la question de l’ordre d’imputation des déficits reportables en avant : il retient une imputation selon un ordre strictement chronologique et en tire les conséquences pour l’application des règles de...more
The General Assembly has recently proposed legislation to update Ohio’s Taxpayer Bill of Rights. House Bill 613 (H.B. 613) has been introduced but not yet assigned to a committee for review. The Bill offers several sweeping...more
The Ohio Board of Tax Appeals (Board) has found that chargebacks, i.e., above the line price reductions, are not discounts to the customer and should not be included in “gross receipts” for Commercial Activity Tax (CAT)...more
Where there is potential for a tax dispute, it is crucial to map your position early: proactively building a “defence” file can best prepare taxpayers for HMRC enquiries when they arise years later. Originally Published in...more
Over the past few weeks, several insurance companies operating in the Italian market have been facing a new wave of tax questionnaires and audits on how to apply the Insurance Premium Tax (IPT) to driver accident (infortuni...more
2025 will be remembered as a year of transition for Canadian taxpayers. The newly elected federal government pivoted away from many controversial Canadian tax policies of the early 2020s, while reaffirming its commitment to...more
It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more
Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more
California residents seeking to change their residency status and avoid California tax must be prepared to substantiate their relocation. Simply moving to another state is not enough to relinquish California residency and tax...more
How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit?...more
Working on an IRS audit is hard enough. But what’s even harder? When you discover the plan sponsor disposed of—or claims to have disposed of, the very records the IRS is demanding....more
The Spanish Supreme Court (judgment of 29 September 2025) reiterates its doctrine regarding the principle of full regularisation (“regularización íntegra”) in VAT matters. The Supreme Court states that Tax Authorities must...more
In a recent decision, the New York Tax Appeals Tribunal issued a sharp reminder to ‘snowbirds’ that changing domicile is about substance, not paperwork. In Matter of John J. Hoff & Kathleen Ocorr-Hoff, DTA No. 850209 (N.Y....more
Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS....more
La CAA de Paris rejette la qualification d’acte anormal de gestion retenue par l’administration fiscale concernant le versement d’indemnités de résiliation anticipée de prêts intragroupe. La Cour relève notamment que la...more
As year-end approaches, it is an opportune time for companies to run an internal audit of their nonqualified deferred compensation plans to flag any potential violations of IRC Section 409A (“Section 409A”)....more
For the last decade, the IRS has proactively asserted discretionary civil tax penalties that can be as high as 40 percent of the proposed tax liability. Oftentimes, the IRS has used penalties as bargaining chips to get...more
For restaurant owners going through a divorce, one of the most contentious financial issues can be non-reporting income, particularly cash earnings. Courts require full financial disclosure, and failure to accurately report...more
As we discussed a few weeks ago, the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection function, the agency may...more
Kilpatrick’s David Hughes recently spoke at the Institute for Professionals in Taxation (IPT) Sales Tax Symposium on “Proactive Sales Tax Strategies for Effective Risk Management and Compliance.” The session addressed...more
A decade ago, the IRS audited and brought cases against numerous taxpayers who claimed residency in the U.S. Virgin Islands to take advantage of a highly touted benefit whereby bona fide Virgin Islands residents could claim a...more
Over the past few months, interest and attention in the world of U.S. tax has been focused on the OBBBA — the One Big Beautiful Bill Act. However, significant administrative and procedural changes have also occurred at the...more